Last updated and effective as of: April 7th, 2019

This website is operated by Tower 28 (“we“ or “us“). The privacy policy below discloses our practices regarding information collection and usage solely for the website located at tower28.com (the “Website”). This privacy policy does not apply to any other website or service provided by us, our affiliates or clients, unless it appears on such website or service. By using and visiting our Website and by submitting your personally identifying information to us you agree to us using your personally identifying information as set out in this privacy policy. If you do not agree to this privacy policy you may not access or otherwise use the Website or service. Use of the Website is also governed by our Terms and Conditions, located at TERMS & CONDITIONS.

We respect the privacy of users of our Website and recognize that when you choose to provide us with information about yourself, you trust us to act in a responsible manner with that information. This privacy policy contains important information about how we use your personally identifying information.

What information do we collect?
We do not collect personally identifying information unless you voluntarily supply us with personally identifying information. Generally, you may provide us with personally identifying information through our contact pages, by email, or some other means. Personally identifying information means information which identifies you as an individual, and may include your name, email address, telephone number, and similar information you provide.

We may automatically collect certain non-personally identifying information about you when you visit the Website, such as the type of browser or device operating system you use, the website that linked you to our Website, the time you spend and the pages you view on the Website. We may also aggregate information collected from Website visitors, such as the number of users in a particular region or having particular characteristics.

How do we use it?
We may use your personally identifying information in the following ways, or any type of use to which you have specifically consented, either at the time the information is collected or through some other form of consent from you or notification to you:
- to operate the Website and provide you with information or services that you have requested e.g. a newsletter, bulletins;
- to add you to our mailing lists and to send you emails from time to time;
- to respond to specific queries you may raise regarding Tower 28 and/or its affiliates; to provide you with better ways of accessing information from this Website;

Non-personal or aggregate information may be shared with any number of parties, provided that such information shall not specifically identify you.

Do we share your information with third parties?
We may send your personally identifying information to other group companies, affiliates and third parties to help us process your personally identifying information for the purposes set out in this policy. We may also permit our vendors and subcontractors to access your personally identifiable information, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.

We may disclose your personally identifying information in connection with a bankruptcy proceeding or if we or any of our assets or divisions are the subject of a sale or similar corporate transaction, including without limitation a merger, acquisition or change of control.

We may disclose personally identifying information to third parties when we reasonably believe we are required by law or legal process, and in order to investigate, prevent, or take action regarding suspected or actual unlawful or otherwise prohibited activities, including, but not limited to, fraud, harassment or other violations of law or the policies of the Website.

Where do we send your information?
Our Website is maintained in the United States of America. By using the Website, you freely and specifically give us your consent to export your personally identifiable information to the USA and to store and use it in the USA as specified in this privacy policy. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA.

How long do we keep your information?If you provide us with personally identifying information through the Website, we retain your information for as long as necessary for our business purposes. This may include, but is not limited to, retaining such information to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your personally identifying information, we may continue to retain and use aggregate or anonymous data previously collected and/or anonymize or aggregate your personally identifying information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

What are cookies?
We may use information obtained from cookies or similar technology (such as clear gifs, web beacons, tags, etc.) for the purpose of facilitating and enhancing your communication and interaction with the Website. Cookies are text files containing small amounts of information which we download onto your computer or device when you visit our Website.

What do we use cookies for?
We may use both first and third-party cookies. First-party cookies are those set by the website that is being visited by the user. Third-party cookies are cookies that are set by a domain other than that of the website being visited by the user. We may use and place third party cookies on your device from our third party service providers in connection with the Website, such as an analytics provider that helps us manage and analyze Website usage. We use the data we collect internally, to help us maintain and enhance the efficiency and usefulness of the Website. We use session ID cookies which are short term cookies that allow us to link the actions of a user during a browser session. Once you close the browser, all session cookies are deleted.

How can you delete cookies?
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge.

What is clickstream data?
As you use the Internet, a trail of electronic information is left at each website you visit. This information, sometimes referred to as “clickstream data”, can be collected and stored by a website’s server. Clickstream data can tell us the type of device and browsing software you use and the address of the website from which you linked to the Website. We may collect and use clickstream data to anonymously determine how much time visitors spend on websites, how visitors navigate throughout web sites and how we may tailor our Website to better meet consumer needs. This information will be used to improve our Website and our services. Any collection or use of clickstream data will be anonymous, and will not intentionally contain any personally identifying information.

Third Party Websites
Our Website may link to third party sites which we do not operate or endorse. These websites may use cookies and collect your personally identifying information in accordance with their own privacy policies. This privacy policy does not apply to third party websites and we are not responsible for third party websites, including without limitation their privacy practices or the content found on such websites. When you link away from our Website, you do so at your own risk. We encourage you to read the policies and terms of every website you visit.

We may also integrate social networking services into the Website. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Website, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.

You should be aware that information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your personally identifying information, and by using such services you assume the risk that the personally identifying information provided by you may be viewed and used by third parties.

How do we protect your information?
We take commercially reasonable measures to ensure that your personally identifying information disclosed to us is kept secure however, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online.

Do we collect personally identifiable information from children under 13?
This Website is not intended or designed to attract children under the age of 13. We do not knowingly collect personally identifying information from or about any person under the age of 13. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

What are your opt-out rights?
To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at hello@tower28.com. We will process your request within a reasonable time after receipt. However, we are not responsible for removing your personally identifiable information from the lists of any third party who has previously been provided with your information in accordance with this privacy policy or your consent.

As noted above, you may opt-out of or restrict the placement of cookies on your device or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on many mobile devices. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

Do Not Track
Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.

California Privacy:
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of personally identifiable information, such as name, email address and mailing address and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us by email through hello@tower28.com.

How to contact us if your information or choices change
If your information or your preferences change, you don't want us to send you the information you have requested or if you have any queries about how we use your personally identifying information, please let us know by contacting hello@tower28.com.

Changes to this privacy policy
We reserve the right, at our discretion, to change, modify, add, or remove portions from this privacy policy at any time. However, if at any time in the future we plan to use personally identifying information in a way that materially differs from this privacy policy, we will post such changes here. You are encouraged to review this privacy policy from time to time.